Dodd-Frank Swap Regulation Starts October 12, 2012: Or Does It?

August 13, 2012 – The publication of a key rule in the Federal Register today has set October 12, 2012, as the start date for Dodd-Frank regulation of swaps and swap dealers by the Commodity Futures Trading Commission (CFTC). On or after this date, firms that qualify as swap dealers or major swap participants (MSPs) must register and comply with several duties. This also is the start date for the phase-in of swap data reporting.

The October 12 deadline is consistent with our prior estimates of when swap dealer registration and swap regulation would begin. Whether any firms will register as dealers on this date is unclear, however.

This FS Regulatory Brief discusses the registration deadline issue in broad terms. It explores the ramifications that different dealer registration deadlines will have on sell- and buy-side firms, including on the start of swap data reporting. Additionally, there are updated timelines showing the key compliance dates for US swap dealers and foreign swap dealers.